First-party auto insurance policies typically extend coverage beyond the named insured to their relatives, as well as others who live with and are economically dependent on them. But who precisely that includes is not always clear. A Delaware court recently held that an insured's live-in boyfriend was not entitled to coverage under her auto policy because he did not qualify as a "relative" or a "household resident," even though he was planning to propose when the accident happened. Lockhart v. Progressive Northern Ins. Co., C.A. No. CPU4-17-001788, 2018 WL 1399612 (Del. Mar. 19, 2018).

Specifically, the boyfriend was not "a relative" because he was not, as the policy stated, "a person residing in the same household as you, and related to you by blood, marriage or adoption, and includes a ward, stepchild, or foster child," even though he intended to propose to the insured when the accident happened. He was also not a "household resident" because he was not economically dependent on the insured.

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